1. The rising significance of digital assets and tokens in Hong Kong

Digital assets, cryptocurrencies and tokens have captured increasing attention in Hong Kong.  For instance, PwC Hong Kong has partnered up with the Sandbox in purchasing a virtual land in the Sandbox metaverse.  NFTs dominate the recent discussions in the blockchain ecosystem.  We also see massive development in the Hong Kong regulatory landscape – the Financial Services and the Treasury Bureau of Hong Kong (“FSTB”) published its consultation conclusion paper proposing a licence regime for virtual assets exchange (the “FSTB Conclusion Paper”) (see our news update here), the recent conclusion paper from the Hong Kong Monetary Authority (the “HKMA“)  focusing on payment-related stablecoins (see our news update here), and a couple of initiatives from the Hong Kong Securities and Futures Commission (“SFC”) on Virtual Assets Service Providers (“VASPs”) and Securities Token Offering (“STO”).  It is therefore important to discuss the different forms of digital assets and their regulatory implications in Hong Kong.

2. What are the different types of digital assets and tokens?

We outline below the various classifications of digital assets.  While by no means exhaustive, they serve as a useful starting point for our discussion.

Digital assets

Broadly speaking, a digital asset is an intangible asset that may be created, traded, and stored in a digital format.  It is a generic term which covers all forms/ classifications of assets to be illustrated below, such as virtual assets, cryptocurrencies, digital tokens, including non-fungible tokens (“NFTs”), and Central Bank Digital Currency (“CBDC”).

Virtual assets

According to the FSTB Conclusion Paper, virtual asset (“VA”) is a digital representation of value that: [1]

(i) is expressed as a unit of account or a store of economic value;

(ii) functions (or is intended to function) as a medium of exchange accepted by the public as payment for goods or services or for the discharge of a debt, or for investment purposes;

(iii) can be transferred, stored or traded electronically; and

(iv) is irrespective of the purported form of underlying assets and whether it is stable or not.

Based on the above definition and as will be further discussed below, the scope of VAs does not cover NFT.  For regulatory purposes, it does not include CBDC. 

VA is sometimes referred to as crypto-asset. There is no universal consensus among the community and the regulators as to which terminology prevails. For example, the term “VA” is deployed by the FSTB whereas “crypto-assets” is used by the HKMA.

Crypto-assets

According to the Financial Stability Board, crypto-asset refers to “a type of private digital asset that depends primarily on cryptography and distributed ledger or similar technology”.[2]

While it is used interchangeably with VAs, crypto-asset includes NFTs, which are a form of cryptographic tokens and not covered under the scope of VA.

Cryptocurrencies

A cryptocurrency is a digital or virtual currency that is secured by cryptography, which makes it almost impracticable to counterfeit or double-spend. It is a sub-set of each of (i) virtual assets and (ii) crypto-assets. The most well-known examples are Bitcoin and Ethereum.

Our other observations are:-

• Cryptocurrencies are based on decentralised blockchain networks and distributed ledger technology.

• It usually refers to the coins or tokens which are fungible in nature (i.e. it is impossible to distinguish one from another of the same kind just by looking at the matter itself).  Due to this nature, they are in general treated as virtual commodities.

• Crypto-assets and cryptocurrencies are often used interchangeably.

• A defining feature of cryptocurrencies is that they are generally not issued by any central authority, rendering them theoretically immune to government interference or manipulation. This distinguishes itself from CBDC.

However, in practice, cryptocurrencies are not fully insusceptible to regulatory actions. In September 2021, the People’s Bank of China announced a blanket ban on all cryptocurrency transactions and mining.  Overseas exchanges are barred from providing services to PRC-based investors.  It also prohibited financial institutions, payment companies and internet firms from facilitating cryptocurrency trading in the PRC.

Stablecoins

Stablecoins are a sub-set of crypto-assets. According to the FSB and the Bank for International Settlements, stablecoins are defined as “a crypto-asset that aims to maintain a stable value relative to a specified asset, or a pool or basket of assets” and “cryptocurrencies with values tied to fiat currencies or other assets” respectively.[3]

Stablecoins can be designed for different purposes with a corresponding backing mechanism. It could be broadly categorised as (i) asset-linked stablecoins; or (ii) algorithm-based stablecoins.  Asset-linked stablecoins are usually pegged to or backed by fiat currencies, commodities (e.g. gold), or other financial assets (e.g. securities). If they are linked to financial assets, arguably they can be considered as securities tokens as well.

CBDC

Unlike stablecoins, CBDC is “a digital form of central bank money that is different from balances in traditional reserve or settlement accounts”.[4] It is a digital payment instrument, denominated in the national unit of account, that is a direct liability of the central bank.  It has a legal status, which distinguishes itself from cryptocurrencies (which are generally decentralised in nature).

The HKMA has explored a technology architecture of CBDC designed to enable households and businesses to hold and make payments with CBDC more safely.

Tokens

Tokens (or cryptographic/ digital tokens) are a digital representation of a physical asset or a utility that blockchain-based organisations or projects develop on top of existing blockchain networks.  A token can have different natures and purposes at the same time.

Other features/ observations include:-

• They can be smart contract embedded.

• The most popular blockchain network for token issuance is the Ethereum (which may be referred to as the blockchain network or the native currency used in such network).

• They are often created on a blockchain protocol (i.e. a set of rules governing the creation and use of such tokens).

• ERC-20 has become the most popular protocol used for the smart contracts on the Ethereum blockchain for token implementation.

• They come in different flavours – utility tokens, security tokens as well as the recently popular non-fungible tokens (“NFTs”), to name a few.

• Notably, NFTs are non-fungible – meaning that each NFT can be made “unique” via the applicable blockchain smart contracted embedded protocol.  Also, since we do not have a standardised form of NFTs at this stage, we would need to have a close look at a particular NFT in order to ascertain its nature.

3. Why is it important to understand the different nature of digital assets?

Such categorisation is useful in understanding the nature of tokens for discussion purpose.  Indeed, depending on the circumstances, the issue of digital assets may or may not attract jurisdiction from the SFC.

Taking NFTs as an example, given the non-standardised nature, some NFTs may be granted with “security”-like features and thus the issue of which would normally be regulated in Hong Kong.  Whether it attracts regulatory scrutiny would require us to take a close look at not only the form but also the substance of such tokens.

Of course, regulation is not necessarily a bad thing – if the token constitutes a “security”, the token holder should deserve additional protection as an investor.  On the other hand, it is important to strike a delicate balance between investor protection and over-regulation.  Given the technicality involved, we encourage issuers especially start-ups to seek advice from professionals in order to understand their relevant legal positions and structure their token issuances accordingly.

If you have any specific plans to conduct a token offering, or would just like to have a general discussion on the above, please feel free to contact our Partner Mr. Rodney Teoh.

This newsletter is for information purposes only. Its content does not constitute legal advice and should not be treated as such.  Stevenson, Wong & Co. will not be liable to you in respect of any special, indirect or consequential loss or damage arising from or in connection with any decision made, action or inaction taken in reliance on the information set out herein.

Background

On 19 November 2021, The Stock Exchange of Hong Kong Limited (the “Exchange”) published its consultation conclusions (the “Consultation Conclusions”) as to its proposal to enhance and streamline the listing regime for overseas issuers.  The amended Rules Governing the Listing of Securities on the Exchange (the “Listing Rules”) and the new guidance materials become effective from 1 January 2022.

The said proposals received large support from the public.  As such, the Exchange has concluded to adopt all the proposals outlined in its consultation paper on enhancing and streamlining the listing regime for overseas issuers on 31 March 2021 (the “Consultation Paper”) with minor modifications.  This article follows up with our news update in April 2021 on the Exchange’s Consultation Paper.  The capitalised terms used herein shall have the same meaning as defined in the Consultation Conclusions and Consultation Paper.  

In summary, the revised listing regime will be based on the following: 

• Streamlining shareholder protection standards into one set of “Core Standards”;
• Relaxing requirements on secondary listing regime for non-WVR Greater China Issuers, (a) without demonstration as an “innovative company”; and (b) lowering the minimum market capitalisation at listing than currently required;
• Allowing Grandfathered Greater China Issuers and Non-Greater China Issuers eligible for secondary listing with their existing WVR and/or variable interest entity structures to opt for a dual primary listing; and
• Publishing new guidance materials for secondary listed issuers.

Key Summary of the Revised Listing Regime

The key points of the revised listing regime of Overseas Issuers are set out as follows.  

Core Shareholder Protection Standards

1. the notice and conduct of general meetings; 
2. members’ right to remove directors, requisition a meeting, vote, speak and appoint proxies or corporate representatives; 
3. the reservation of auditor appointment, etc. to a committee independent of the board of directors of a company or a majority of the shareholders and the reservation of certain other material matters to supermajority votes by shareholders; 
4. restrictions on the term of a director appointed to fill a casual vacancy; 
5. availability of the shareholders’ register for inspection; and
6. restrictions on shareholder voting on certain matters required by the Listing Rules.  

Dual Primary Listing

Secondary Listing Requirements

Criteria A 

1. a track record of good regulatory compliance of at least five full financial years on a Qualifying Exchange (for any Overseas Issuer without a WVR structure) or on any Recognised Stock Exchange (only for Overseas Issuers without a WVR structure and without a centre of gravity in Greater China); and 
2. an expected market capitalisation at the time of secondary listing of at least HK$3 billion. 

Criteria B

1. a track record of good regulatory compliance of at least two full financial years on a Qualifying Exchange; and 
2. an expected market capitalisation at the time of secondary listing of at least HK$10 billion.

Secondary listed issuers’ conversion to primary listing status

• Route 1 – For issuers delisted from the overseas exchange: 
  1. A 12-month automatic grace period available for the preparation of financial statements in accordance with HKFRS/ IFRS upon delisting from the primary listing market.
  2. Automatic Waivers will be disapplied in respect of other Listing Rules upon being delisted from the primary listing market.
  3. Regarding involuntary delisting from the overseas exchange, transitional arrangements shall apply for continuing transactions which are entered into before the issuer’s notification of the involuntary delisting to the Exchange so that the transactions are exempt from applicable Listing Rules for 3 years from the date of the delisting notification. 
  4. In the event that an Overseas Issuer expects difficulty in complying with specific applicable Listing Rules, a grace period may be granted on a case-by-case basis. The Exchange reserves the power to require the issuer’s stock short name to include a special stock marker (TP) to indicate that the issuer is a primary listed issuer under transitional arrangements.

• Route 2 – For issuers that become primary listed in Hong Kong as a result of Migration: 
  1. Upon the majority of trading in the Overseas Issuer’s listed shares (i.e. 55% or more of the total worldwide trading volume, by dollar value, of those shares) migrates to the Exchange’s markets on a permanent basis over the overseas issuer’s most recent financial year, all Automatic Waivers will be revoked subject to the existing transitional arrangements of Chapter 19C.

• Route 3 – For issuers that become dual primary listed in Hong Kong as a result of Primary Conversion:
  1. All Automatic Waivers shall be revoked upon the effective date of Primary Conversion and a grace period for full compliance with the Listing Rules will not normally be allowed.

Analysis and Takeaways

The revised listing regime enhances and streamlines the Exchange’s approach to Overseas Issuer listings as a whole.  It clarifies the applicable requirements, thereby creating incentives for overseas issuers primary listed elsewhere to explore possibilities of applying for dual primary listing or secondary listing on the Exchange.  Some of the more restrictive requirements for issuers with a centre of gravity in Greater China have been removed, and it is expected to attract more US-listed Greater China Issuers to seek “homecoming” secondary listing attempts on the Exchange.

Please contact our Partner Mr. Rodney Teoh for any enquiries or further information.

This newsletter is for information purposes only. Its content does not constitute legal advice and should not be treated as such. Stevenson, Wong & Co. will not be liable to you in respect of any special, indirect or consequential loss or damage arising from or in connection with any decision made, action or inaction taken in reliance on the information set out herein.

Introduction

On 1 November 2018, the Securities and Futures Commission (the “SFC”) released the “Statement on Regulatory Framework for Virtual Asset Portfolios Managers, Fund Distributors and Trading Platform Operators” (the “Statement”). The Statement, together with its appendices entitled “Regulatory standards for licensed corporations managing virtual asset portfolios” (Appendix 1) and “Conceptual framework for the potential regulation of virtual asset trading platform operators” (Appendix 2) and also a circular to the intermediaries on “Distribution of Virtual Asset Funds” (the “Circular”) issued on the same date (altogether, the “Regulatory Documents”) provide a summary of the regulatory standards applicable to virtual asset portfolio managers, fund distributors and trading platform operators. They also clarify SFC’s regulatory stance and approach towards the involvement of digital assets in investment activities.

The SFC reminds the intermediaries of the importance of having reference to the relevant requirements set out in the Regulatory Documents by the more recent release of the “Statement on Security Token Offering” on 28 March 2019.  The Statement reminds intermediaries to observe and ensure compliance with the requirements similar to those set out in the Circular before they engage in the distribution of security token offerings (STOs). Failure to do so may affect their fitness and properness to remain licensed or registered and may result in disciplinary action by the SFC.

Background

Set out below are the material announcements or statements released or actions taken by the SFC in relation to the regulation of virtual assets or commodities leading to the release of the Regulatory Documents:-

On the other hand, on 28 March 2019, the SFC released the “Statement on Security Token Offering”, which reminds market participants that licensing and registration requirements shall apply to the marketing and distribution of security tokens that are “securities” (unless applicable exemption applies).

In this update, we will focus on the SFC’s regulatory approach on virtual asset portfolio managers, fund distributors and trading platform operator.

Status of virtual assets and virtual asset funds

The Regulatory Documents have not provided an exhaustive list of virtual assets which constitute “securities” or “futures contracts”. Whether certain virtual assets constitute “securities” or “futures contracts” shall remain to be determined on a case by case basis in the light of the terms and features of that particular kind of virtual assets. The SFC has quoted in the past the following examples of virtual assets being “securities”[1]:-

(1)         Digital tokens representing equity or ownership interests in a corporation such as tokens which give holders shareholders’ rights including the right to receive dividends and the right to participate in the distribution of the corporation’s surplus assets upon winding up;

(2)         Digital tokens used to create or to acknowledge a debt or liability owed by the issuer, such that an issuer may repay token holders the principal of their investment on a fixed date or upon redemption, with interest paid to token holders; and

(3)         Digital tokens the proceeds of which are managed collectively by the ICO scheme operator to invest in projects with an aim to enable token holders to participate in a share of the returns provided by the project (which is regarded by the SFC as a CIS).

In the Black Cell Incident, the SFC identified, among others, the following characteristics of the ICO concerned:-

(i)            The ICO was for the sale of digital tokens to investors through its website accessible by the Hong Kong public;

(ii)          The ICO was with the pitch that the ICO proceeds would be used to fund the development of a mobile application; and

(iii)         Holders of the tokens will be eligible to redeem equity shares of Black Cell.

Further, interest in a fund investing in the virtual assets, being interest in a CIS, shall also constitute “securities” as defined under the SFO.

Summary of the new regulatory standards for licensed corporations managing and distributing virtual asset portfolios

The SFC clarified in the Regulatory Documents that distributing a fund that invests solely in virtual assets which do not amount to “securities” or “futures contracts” requires a licence of Type 1 regulated activity (dealing in securities).  It further announced that all licensed corporations investing or intending to invest in virtual assets exceeding 10% of the gross asset value of the portfolio in virtual assets, and distribute the same, should be subject to a set of standard terms and conditions (the “Terms and Conditions”) (subject to minor variations and elaborations depending on the licensed corporations’ business models), irrespective of whether the virtual assets involved amount to “securities” or “futures contracts”.

The Terms and Conditions will be imposed by way of licensing conditions, a summary of which is set out below.

Additional requirements regarding (1) selling restrictions and concentration assessments; (2) due diligence on the virtual asset funds; and (3) information for clients set out therein are also imposed on licensed corporations distributing virtual asset funds which are not authorised by the SFC.

Practical aspects concerning the application of the new Terms and Conditions

On 1 June 2018, the SFC has issued a circular to remind intermediaries to notify the SFC regarding changes to be introduced to their business activities to provide trading and asset management services involving crypto-assets as well as robo-advisory financial services. The positive obligation to notify continues to apply to licensed corporations. Specifically, the Regulatory Documents, require the licence applicants and licensed corporations to inform the SFC (i) if they are presently managing, or planning to manage, one or more portfolios that invest in virtual assets; or (ii) if they intend to hold virtual assets on behalf of the portfolios under their management.

Upon being aware of any firm managing or planning to manage virtual asset portfolios, the SFC will first seek to understand the firm’s business activities.

If the firm appears to be capable of meeting the expected regulatory standards, the standard Terms and Conditions will be provided to the firm and the SFC will discuss and vary them with the firm in light of its business model so as to ensure that the Terms and Conditions applicable to the firm are reasonable and appropriate.

If a licence applicant does not agree to comply with the proposed terms and conditions, its licensing application will be rejected. Similarly, if an existing licensed corporation does not agree to comply with the proposed terms and conditions, it shall not manage any virtual asset portfolios. If any such licensed corporation is presently managing virtual asset portfolios, it will be required to unwind the virtual asset positions in these portfolios within a reasonable period of time, taking due account of the interests of the portfolios’ investors.

After the licence applicant or licensed corporation has agreed with the proposed Terms and Conditions, they will be imposed through licensing conditions. Failure to comply with them may be considered as misconduct under the SFO. The SFC considers that this will reflect adversely on a licensed corporation’s fitness and properness and may result in the SFC taking regulatory action.

The potential regulation of virtual asset trading platform operators

The SFC has also issued the “Conceptual framework for the potential regulation of virtual asset trading platform operators” among the Regulatory Documents (the “Conceptual Framework”), which sets out SFC’s regulatory approach to virtual asset trading platforms (commonly known as cryptocurrency exchanges).

Virtual asset trading platforms are online platforms which match buyers’ and sellers’ orders for trading in virtual assets, and they perform functions similar to traditional securities brokers, stock exchanges and private trading venues (e.g., alternative liquidity pools). Investors usually buy, sell or trade virtual assets on these platforms.

In the Conceptual Framework, the SFC indicated that it is now at the initial exploratory stage to explore how virtual asset platform operators (the “Platform Operators”) can be regulated. Interested Platform Operators who are committed to adhering to the SFC’s high standards may opt into the SFC Regulatory Sandbox (the “Sandbox”), through which the SFC would discuss its expected regulatory standards with the Platform Operators and observe the live operations of the virtual asset trading platforms in light of these standards. If the SFC makes a positive determination, it would then consider granting a licence to a qualified Platform Operator, subject to licensing conditions.

Should the SFC conclude that it may grant a licence to a qualified Platform Operator, the Platform Operator is expected to comply with the SFO, the Code of Conduct and all applicable guidelines, circulars and frequently asked questions published by the SFC from time to time. Additionally, the SFC will impose certain licensing conditions under section 116(6) of the SFO to address the specific risks associated with a Platform Operator’s operations.

The Conceptual Framework further sets out five core principles and other specific terms and conditions which are likely to be included as licensing conditions, subject to modifications and discussion between the SFC and the Platform Operator in the Sandbox. These core principles include:

(1)         Carrying out all virtual asset trading business activities (the “Relevant Activities”) under a single legal entity licensed by the SFC;

(2)         Complying with all applicable regulatory requirements for all Relevant Activities, notwithstanding that the activities may not relate to virtual assets which are “securities”;

(3)         provision of services only to “professional investors”;

(4)         admitting a virtual asset issued by way of an initial coin offering for trading on its platform at least 12 months after the completion of the ICO or when the ICO project has started to generate profit, whichever is earlier; and

(5)         executing a trade for a client only if there are sufficient fiat currencies or virtual assets in his account with the platform to cover that trade.

Proposed terms and conditions

In addition to the core principles, where the existing requirements may not be directly applicable or where the SFC considers enhanced investor protection measures necessary, the SFC may impose as licensing conditions additional terms and conditions in respect of:-

(1)         financial soundness of the Platform Operator;

(2)         taking out of insurance policy by the Platform Operator;

(3)         assessment of client’s knowledge of virtual assets;

(4)         adoption of anti-money laundering and counter-financing of terrorism systems;

(5)         disclosure of nature and risks in trading the virtual assets, fees chargeable by the Platform Operators, etc.;

(6)         due diligence to be performed on the virtual assets;

(7)         preparation and publication of trading rules governing its platform operations;

(8)         prevention of market manipulative and abusive activities;

(9)         establishment and maintenance of policies and procedures governing employees’ dealings;

(10)      proprietary trading;

(11)      segregation and custody of clients’ money and virtual assets; and

(12)      ongoing reporting obligations.

Way forward

To market participants and the legal community, the Regulatory Documents represent an attempt by the SFC to further develop its approach towards the regulation of digital assets in investment activities.

In view of the positive obligations to notify the SFC in relation to their intention to maintain portfolios that invest in virtual assets and other material changes to portfolios that are under their management, licensed corporations should be vigilant and take steps to ensure that they comply with the requirements in force and applicable licensing conditions.

Overall, since the SFC is still developing its regulatory stance and approach, more policies and legal changes may be underway. Market participants shall stay alert to further changes and assess the relevant impacts on their businesses. Whilst some official avenues, such as the Regulatory Sandbox, are available for market participants to understand details of the relevant new arrangement, it may be advisable in the circumstances to consult professional legal advice first before engaging in a dialogue with the regulator.

This newsletter is for information purposes only. Its content does not constitute legal advice, and should not be treated as such. Stevenson, Wong & Co. will not be liable to you in respect of any special, indirect or consequential loss or damage arising from or in connection with any decision made, action or inaction taken in reliance on the information set out herein.

Please contact our Hank Lo or Rodney Teoh for any enquiries or further information.

Background

On 22 March 2019, the Exchange published a listing decision (LD121-2019) to provide guidance on the reasons for rejecting 24 listing applications. The Exchange acknowledged that there was a noticeable increase in the number of listing applications rejected in 2018 as compared to previous years. The aforementioned increase was due to a heightened level of scrutiny exercised by the Exchange in its assessment of suitability of listing applicants (the “Applicant(s)”), and the exercise of its discretion to determine whether there are facts and circumstances to form a reasonable basis to believe that the Applicants are likely to invite speculative trading upon listing or to be acquired for their listing status. The Exchange placed particular emphasis on the Applicants’ (1) commercial rationale for listing and whether there was a genuine need for funding, and (2) valuation and the methodology used, when vetting the listing applications.

Summary

The table below provides a summary of the reasons for rejection raised by the Exchange:

Conclusion

The listing decision reflects (1) the change in the Exchange’s listing reviewing process; and (2) the new initiatives of the Exchange shown in recent developments such as (a) the GEM Listing Rules amendments in February 2018; and (b) the Consultation Paper regarding Backdoor Listing published in June 2018. For further details, please refer to our news updates published on 5 March 2018 and 11 September 2018.

This newsletter is for information purposes only.  Its content does not constitute legal advice, and should not be treated as such.  Stevenson, Wong & Co. will not be liable to you in respect of any special, indirect or consequential loss or damage.

Please contact our Hank Lo or Rodney Teoh for any enquiries or further information.

SW acted as legal advisers to International Alliance Financial Leasing Co., Ltd. (Stock Code: 1563) (“IA Finance Leasing”) in its successful listing on the Main Board of The Stock Exchange of Hong Kong Limited (the “Stock Exchange”). IA Finance Leasing offered a total of 495 million shares, which were listed on the Stock Exchange on 15 March 2019.

SW Partner Mr. Rodney Teoh and Mr. Li Luqiang (IA Finance Leasing: Executive Directors)

IA Finance Leasing and its subsidiaries (the “Group”) are a finance leasing company headquartered in Beijing, providing finance leasing and advisory services. The Group targets customers in three targeted industries in the PRC, including the healthcare, aviation and public infrastructure industries. During the track record period, the Group had customers across 17 provinces, two autonomous regions and one municipality in the PRC also one customer incorporated in Singapore and one customer incorporated in the BVI.

Ms. Xu Juan (IA Finance Leasing: Executive Directors) and SW Partner Mr. Rodney Teoh

Mr. Lau Kwok Fai Patrick (IA Finance Leasing: Chief Financial Officer and Company Secretary) and SW Partner Mr. Rodney Teoh

SW Partner Mr. Rodney Teoh, Mr. Michael Tang (Cinda: Executive Director), Mr. Dickson Lau (Cinda: Deputy CEO & Executive Director), Mr. Francis Yeung (Cinda: Managing Director) and SW Partner Mr. Hank Lo

The sole sponsor of the Listing was Cinda International Capital Limited. The joint global coordinators of the Global Offering were Cinda International Capital Limited, ChaoShang Securities Limited and CCB International Capital Limited.

Ms. Florence Wai, Ms. Claire Sit, Mr. Rodney Teoh, Mr. Hank Lo, Mr. Kristopher Wong and Miss Myra Ma

Our team was led by our partners Hank Lo and Rodney Teoh, supported by team members including Kristopher Wong (associate), Florence Wai (associate), Claire Sit (associate) and Myra Ma (trainee solicitor).

Please contact our Mr. Hank Lo or Mr. Rodney Teoh for any enquiries or further information.